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281 Kan. 392

State v. Bunyard

Supreme Court of Kansas

Decided April 28, 2006

Supreme Court of Kansas · decided 2006-04-28

Key passage — most relied on by later courts

“"A person may be convicted of rape if consent is withdrawn after the initial consensual penetration but intercourse is continued by the use of force or fear. However, when consent is withdrawn after penetration the defendant is entitled to a reasonable time in which to act after the withdrawn consent is communicated to the defendant. Whether the termination of intercourse occurs within a reasonable time is to be determined by the jury, taking into account the manner in which consent was withdrawn and the particular facts of each case. [Citation omitted.]"”

quoted by 1 later decision, including 45 Kan. App. 2d 1113 - State v. Flynn

Good law ✅— No negative treatment on recordhow we know

Decided 2006-04-28

How this case has been cited

Cited by 50 later decisions — most recently January 2021 · most notably State v. Inkelaar (2011), State v. Hall (2011)

50 state decisions

370200620102020decided

Later decisions citing this case, by decade. The current decade is in progress, and our corpus holds fewer opinions from the most recent years, so the latest bars are undercounted — not a real decline.

View the full empirical analysis of this case →

Luckert, J.,

¶1dissenting in part and concurring in part: I join Chief Justice McFarland’s dissent. Additionally, although I concur in the majority’s holding that rape can occur post-penetration, I dissent from the majority’s conclusion that a defendant who is charged with rape under K.S.A. 2004 Supp. 21-3502(a)(l)(A) “is entitled to a reasonable time in which to act after consent is withdrawn.”

¶2The majority does not explain how a juiy should interpret “reasonable time” when a defendant is charged with rape under K.S.A. 2004 Supp. 21-3502(a)(l)(A), which requires the State to prove the victim was overcome by force or fear. There are two possible readings of the majority holding. The presence of an ambiguity is, in itself, troubling. Additionally, both of the potential interpretations are problematic.

¶3Under one interpretation, the majority, by allowing a reasonable time to act, may be implicitly recognizing that persistence is sufficient to satisfy the requirement of force after penetration has occurred. Yet, the majority would reverse the conviction in this case because the prosecutor stated, “The force of his penis in her vagina is enough under the law of the State of Kansas.” Does this mean that tire physical contact inherent in intercourse cannot satisfy the element of force when there is no consent before penetration but may be sufficient force to constitute rape when the consent is withdrawn post-penetration? The potential dichotomy is troubling.

¶4The alternative reading is even more troubling. If the majority opinion is read to require more force than mere persistence, the effect of tire ruling is to grant a defendant a safe harbor of “reasonable time” during which the defendant may exert this higher degree of force or strike fear in the victim.

¶5*425I would hold that a defendant has committed rape if, after consent is withdrawn, the act of intercourse continues as the result of force or fear. This holding is consistent with the elements defined by K.S.A. 2004 Supp. 21-3502(a)(l)(A). The court should not judicially add a defense allowing a reasonable time in which to commit rape.

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